Climate Change, Human Rights and the Legal Limits of State Discretion: A Commentary on State of the Netherlands v Stichting Urgenda

Author: Ramsha Saeed
B.A. LL.B. Candidate, Shambhunath Institute of Law, Prayagraj, India.

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CASE AT A GLANCE

Particular	Details
Case	State of the Netherlands v Stichting Urgenda
Court	Supreme Court of the Netherlands
Date	20 December 2019
Case No. / ECLI	No. 19/00135; ECLI:NL:HR:2019:2007
Area of Law	Climate Change Law; Environmental Law; Human Rights; Constitutional Law
Key Provisions	Articles 2, 8 and 13 of the European Convention on Human Rights (ECHR); Articles 3:305a and 6:162 of the Dutch Civil Code
Central Issue	Whether the Dutch State was legally required to adopt sufficiently effective measures to protect residents against the serious risks associated with dangerous climate change.
Holding	The Supreme Court dismissed the State’s appeal and upheld the emissions-reduction order made by the lower courts.
Ratio	Articles 2 and 8 ECHR may impose positive obligations requiring the State to take appropriate and effective measures against serious and foreseeable climate-related risks. The global nature of climate change does not excuse an individual State from making an appropriate contribution.
Significance	The judgment established a landmark model of rights-based climate accountability while preserving substantial governmental discretion over the policy measures used to comply with legal obligations.

Abstract

State of the Netherlands v Stichting Urgenda represents a defining development in rights-based climate litigation. In December 2019, the Supreme Court of the Netherlands upheld an order requiring the Dutch State to strengthen its mitigation efforts and reduce greenhouse-gas emissions in accordance with the minimum level established by the lower courts. The decision connected climate mitigation with the State’s positive obligations under Articles 2 and 8 of the European Convention on Human Rights.

This commentary argues that Urgenda is best understood neither as an instance of judicial climate policymaking nor as an unrestricted invitation to courts to supervise environmental policy. Rather, it establishes a model of rights-based accountability in which courts may enforce a minimum legal standard while leaving the selection of policy instruments to democratically accountable institutions. The judgment’s principal strength lies in its treatment of serious climate risk as capable of engaging existing human-rights obligations. Its limitations arise from the difficulty of translating scientific consensus into legally enforceable standards and determining what constitutes a State’s appropriate contribution to a collective global problem.

Keywords: Climate Change; Human Rights; Positive Obligations; State Responsibility; Climate Litigation.

I. Introduction

Climate change presents an acute challenge to conventional legal categories. Its causes are cumulative, geographically dispersed, and historically uneven, while its consequences may materialise across national borders and over generations. Yet the harms associated with dangerous climate change are experienced locally and may directly affect life, homes, private and family life, health, and human security. The resulting legal question is therefore increasingly difficult to confine to the sphere of political discretion: when a government recognises a serious climate risk but adopts measures that are arguably insufficient to address it, can a court require more?

The Supreme Court of the Netherlands answered that question affirmatively in State of the Netherlands v Stichting Urgenda.[1] On 20 December 2019, the Court dismissed the State’s appeal and upheld the order requiring the Netherlands to strengthen its greenhouse-gas mitigation efforts in accordance with the minimum reduction standard affirmed by the Dutch courts.[2] The Court located the State’s obligation principally in the positive duties arising from Articles 2 and 8 of the ECHR, which protect, respectively, the right to life and the right to respect for private and family life and the home.[3]

The judgment has frequently been described as a landmark in global climate litigation. That description is justified, but its legal significance requires careful qualification. Urgenda did not establish a universal judicial power to prescribe national climate policy. Nor did the Supreme Court hold that the Paris Agreement independently imposed a legally enforceable national emissions target. The numerical standard upheld in the case emerged from the particular evidentiary and legal context before the Court, including scientific assessments and internationally recognised mitigation pathways for developed countries, or Annex I countries.[4]

This commentary argues that Urgenda is best understood as a judgment concerning rights-based accountability rather than judicial climate governance. Its central contribution lies in recognising that governmental discretion in climate policy is constrained by legally enforceable duties where serious and foreseeable risks threaten fundamental rights. At the same time, the judgment preserves institutional boundaries by distinguishing between the legal minimum required of the State and the policy means through which compliance may be achieved.

The discussion examines the factual and procedural history of the litigation, the issues and arguments before the Supreme Court, and the Court’s holding and reasoning. It then evaluates the strengths and limitations of the rights-based approach adopted in Urgenda, before considering its preventive, intergenerational, and global implications.

II. Facts and Procedural History

Stichting Urgenda (“Urgenda”) is a Dutch foundation engaged in promoting the transition towards a more sustainable society and developing measures aimed at preventing dangerous climate change.[5] In 2013, Urgenda initiated civil proceedings against the State of the Netherlands. It acted both in its own capacity and as representative of 886 individuals identified in the proceedings.[6]

Urgenda’s claim was founded on the proposition that the State’s approach to greenhouse-gas mitigation was insufficient to protect those affected by the risks of dangerous climate change. It sought an order requiring the State to reduce Dutch greenhouse-gas emissions by 40 per cent, or at least 25 per cent, by the end of 2020 compared with 1990 levels.[7] The State’s policy at the time contemplated a reduction of approximately 17 per cent by 2020.[8]

On 24 June 2015, the District Court of The Hague delivered the first judicial decision in the litigation.[9] It ordered the State to limit the annual volume of Dutch greenhouse-gas emissions so that they would be at least 25 per cent below 1990 levels by the end of 2020.[10] The District Court principally approached the matter through the Dutch law of tort and the State’s duty of care under Article 6:162 of the Dutch Civil Code.[11]

An important procedural distinction emerged at this stage. The District Court did not treat Urgenda as a “victim” entitled to invoke the ECHR through the individual application mechanism under Article 34 ECHR.[12] Instead, Urgenda’s capacity to pursue collective protection arose under Dutch law, particularly Article 3:305a of the Dutch Civil Code, which permits certain foundations and associations to bring collective actions in protection of comparable interests.[13] The distinction between Convention victim status and domestic collective standing remained important in understanding the case’s procedural framework.

The State appealed. On 9 October 2018, the Hague Court of Appeal upheld the District Court’s order in State of the Netherlands v Stichting Urgenda, ECLI:NL:GHDHA:2018:2591.[14] While the result remained unchanged, the Court of Appeal significantly shifted the legal basis of the judgment. It relied substantially upon the positive obligations arising under Articles 2 and 8 ECHR and concluded that the State had a duty to provide protection against the serious risks associated with dangerous climate change.[15]

The State subsequently appealed to the Supreme Court. The Procurator General’s Office issued an advisory opinion in September 2019 recommending that the Court of Appeal’s judgment be upheld.[16] On 20 December 2019, the Supreme Court dismissed the State’s appeal and affirmed the lower courts’ approach to the minimum level of emissions reduction required in the circumstances.[17]

III. Issues Before the Court

The litigation raised five principal legal issues.

First, could Articles 2 and 8 ECHR impose positive obligations upon the Dutch State in relation to the risks created by dangerous climate change?

Secondly, did the collective and global nature of climate change prevent an individual State from bearing legal responsibility for its own contribution to mitigation?

Thirdly, did the scientific and international material relied upon in the proceedings support the emissions-reduction standard upheld by the lower courts?

Fourthly, how did the procedural framework reconcile Convention victim status under Article 34 ECHR with Urgenda’s ability to bring a collective action under Article 3:305a of the Dutch Civil Code?

Finally, did judicial enforcement of a minimum mitigation obligation constitute an impermissible intrusion into the discretion of the legislative and executive branches?

IV. Arguments of the Parties

A. Urgenda’s Arguments

Urgenda argued that climate change created a serious and foreseeable danger to present and future residents of the Netherlands. It relied upon scientific assessments concerning the consequences of rising global temperatures and maintained that the State’s existing mitigation policy failed to provide adequate protection against those risks.[18]

Urgenda further argued that the Netherlands could not avoid responsibility by relying upon the comparatively limited proportion of global emissions attributable to Dutch territory. Climate change was undoubtedly a collective problem, but its collective character required participation by individual States rather than permitting each State to rely upon the insufficiency of its contribution when considered in isolation.

The foundation’s legal argument drew upon Dutch tort law, particularly the State’s duty of care, and the protective obligations associated with Articles 2 and 8 ECHR.[19] It maintained that the State was required to take stronger mitigation measures and relied on scientific and international materials supporting substantially greater emissions reductions by developed countries.[20]

B. The State’s Arguments

The State disputed that it was subject to a legally enforceable obligation to achieve the specific level of reduction sought by Urgenda. It argued that the relevant international climate objectives and scientific assessments did not establish a binding domestic legal rule prescribing the reduction level requested by the claimants.[21]

The State also relied upon the global nature of climate change. Dutch emissions constituted only a fraction of worldwide emissions, and a reduction by the Netherlands alone could not independently resolve the problem of global warming.[22]

A further objection concerned the institutional competence of the judiciary. Climate policy involves difficult choices concerning energy, industry, infrastructure, public expenditure, and international cooperation. The State maintained that these choices were fundamentally political and that the determination of climate policy therefore belonged principally to the democratically accountable branches of government.[23]

V. The Holding

The Supreme Court dismissed the State’s appeal and upheld the emissions-reduction order made by the lower courts.[24]

The Court’s central legal holding was that Articles 2 and 8 ECHR can impose positive obligations upon a State to take appropriate and effective measures where a real and serious risk threatens the rights protected by those provisions. The Court concluded that dangerous climate change constituted such a risk and that the Dutch State was therefore required to provide adequate protection.[25]

The Court also rejected the proposition that the global nature of climate change relieved the Netherlands of legal responsibility. A State may bear only partial responsibility for a global problem, but partial responsibility remains responsibility. The Netherlands was therefore required to make an appropriate contribution to the collective effort to prevent dangerous climate change.[26]

The holding must, however, be distinguished carefully from broader claims sometimes made about the case. The Supreme Court did not hold that the Paris Agreement itself imposed a directly enforceable national reduction target. Nor did it create a universal numerical rule applicable to every State. The reduction standard affirmed in Urgenda reflected the particular scientific evidence, international materials, and legal circumstances considered by the Dutch courts.[27]

The Court further held that judicial review did not violate the separation of powers. The judiciary could determine whether the State had complied with its legal obligations, while the State retained substantial discretion concerning the measures through which those obligations would be fulfilled.[28]

VI. The Court’s Reasoning

A. Positive Obligations Under Articles 2 and 8 ECHR

The doctrinal foundation of Urgenda lies in the positive obligations associated with Articles 2 and 8 ECHR.

Article 2 protects the right to life. Article 8 protects the right to respect for private and family life and the home. Neither provision expressly refers to climate change. Their relevance therefore depended upon the established jurisprudence of the European Court of Human Rights (“ECtHR”), which recognises that States may be required to take reasonable and appropriate measures where serious environmental or other risks threaten interests protected by the Convention.[29]

The Supreme Court applied that framework to climate change. It accepted that dangerous climate change posed a serious risk to life and to the conditions necessary for the enjoyment of private and family life.[30] The State could not simply await the materialisation of irreversible harm where the risk had already become sufficiently serious and foreseeable.

The significance of this reasoning lies in its doctrinal method. The Court did not recognise an autonomous and free-standing right to a stable climate. Instead, it interpreted existing Convention rights in light of an environmental threat capable of undermining their effective enjoyment.

B. The Global Problem and Individual Responsibility: The Duty to “Do Its Part”

The State’s reliance upon the limited proportion of global emissions attributable to the Netherlands presented a fundamental problem of climate responsibility. No individual State can solve climate change alone. If that fact were sufficient to negate legal responsibility, however, every State could invoke the same argument and collective action would become legally unenforceable.

The Supreme Court rejected that logic. It reasoned that the collective character of climate change did not eliminate the individual responsibility of States.[31] The Netherlands was required to make an appropriate contribution, or to “do its part”, within the sphere of its own responsibility and control.[32]

This principle should not be overstated. The Court did not create a comprehensive legal formula capable of allocating the global carbon budget among States. Nor did it resolve every question concerning historical responsibility, per capita emissions, or differentiated national capacities. Its proposition was narrower: the fact that other States also contribute to a global danger does not release a State from its own protective obligations.

The judgment thus addresses a central accountability problem in climate law. Collective causation does not necessarily imply collective legal impunity.

C. Scientific Evidence and the Mitigation Standard

The Supreme Court’s assessment of the mitigation obligation was closely connected to scientific evidence and international climate developments.

The Court considered the Fourth Assessment Report (“AR4”) of the Intergovernmental Panel on Climate Change (“IPCC”), published in 2007. The relevant mitigation scenario associated with limiting warming identified a reduction range of 25 to 40 per cent below 1990 levels by 2020 for Annex I countries as a group.[33] Annex I countries are the industrialised countries and economies in transition listed in Annex I to the United Nations Framework Convention on Climate Change (“UNFCCC”).[34]

The State argued that the range applied to Annex I countries collectively rather than establishing an identical obligation for each State. The Supreme Court accepted that the range had been formulated for the group but considered that the international climate framework was also founded upon individual State responsibility. In the absence of an agreement allocating the relevant burden differently, the Court considered the scientific and international material capable of informing the State’s minimum protective obligation.[35]

The Court also considered developments following AR4, including the Paris Agreement’s objective of holding the increase in global average temperature to well below 2°C above pre-industrial levels and pursuing efforts to limit the increase to 1.5°C.[36] The Paris Agreement was relevant to the Court’s assessment of the continuing seriousness of the mitigation challenge and the broader international consensus concerning the need for ambitious action.

However, the legal significance of the Paris Agreement requires precision. The Supreme Court did not treat the Agreement as independently imposing the precise emissions reduction ordered in Urgenda. The standard upheld by the Court remained tied to the specific evidence and legal context of the case.[37]

The Court therefore used scientific evidence and international consensus to inform the substantive content of an existing legal obligation under Articles 2 and 8 ECHR. It did not simply convert scientific recommendations or international policy aspirations into directly enforceable domestic rules.

D. Separation of Powers: The Legal Floor and the Policy Means

The State’s separation-of-powers argument raised the most significant constitutional objection to the judgment.

Climate policy necessarily requires choices about economic development, energy systems, industrial regulation, and public expenditure. Courts do not possess the democratic mandate ordinarily associated with making those choices.

The Supreme Court accepted that the political branches retained substantial discretion in determining how to pursue climate policy. Yet that discretion operated within legal limits. Where the State was subject to directly effective human-rights obligations, the judiciary retained responsibility for determining whether those obligations had been fulfilled.[38]

The distinction between result and means was therefore central. The judgment required the State to meet a minimum legal standard of protection, but it did not prescribe the specific legislative or administrative measures through which compliance had to be secured.[39]

This distinction supports the judgment’s institutional legitimacy. The Court did not redesign the Dutch energy system or enact a climate programme from the bench. It enforced what it regarded as a legal floor, while leaving the selection of policy means primarily to the institutions constitutionally responsible for making them.

VII. Critical Analysis

A. The Strength of Rights-Based Climate Litigation

The strongest feature of Urgenda is its recognition that climate risk can engage existing legal rights.

Climate governance has traditionally depended heavily upon international negotiations, domestic legislation, and administrative regulation. These mechanisms are indispensable but may be vulnerable to political delay and weak implementation. By connecting climate risk to enforceable rights, Urgenda created an additional mechanism of accountability.

The decision is particularly significant because climate harm is cumulative and temporally extended. If legal protection depended upon waiting until environmental damage became immediate or irreversible, the preventive capacity of human-rights law would be severely constrained.

The judgment therefore demonstrates the capacity of existing rights to respond to emerging forms of environmental harm without requiring the prior creation of an entirely new climate-specific right.

B. Judicial Restraint as a Source of Legitimacy

The judgment’s legitimacy is strengthened by the limits it placed upon judicial intervention. Courts are not ordinarily equipped to design detailed national climate strategies. A judicial order prescribing specific taxes, technologies, or energy sources would raise serious institutional and democratic concerns.

The Supreme Court avoided that approach. It enforced a minimum legal standard while leaving implementation to the State. This distinction permits courts to protect legal rights without assuming responsibility for comprehensive policymaking.

The model adopted in Urgenda may therefore be described as one of judicial boundary-setting. The political branches retain discretion, but that discretion cannot extend below the minimum level of protection required by law.

C. The Difficulty of Converting Scientific Knowledge into Legal Standards

The judgment nevertheless reveals a persistent difficulty in climate adjudication: science can identify risks and model mitigation pathways, but legal systems must determine what follows normatively from those findings.

Scientific assessments frequently provide ranges, scenarios, and probabilities rather than single legally determinative outcomes. Translating such material into a judicially enforceable obligation therefore requires an additional legal judgment concerning responsibility, timing, and adequacy.

The Supreme Court addressed this challenge through reliance on a substantial body of scientific and international material. Yet future cases may present less settled evidence or greater disagreement about the appropriate response to a particular climate risk.

Urgenda therefore does not eliminate the science-to-law problem. Rather, it demonstrates one judicial method of addressing it: using scientific consensus to inform the content of independently existing legal obligations.

D. The Limits of the “Do Your Part” Principle

The Court’s rejection of the small-emitter argument is normatively compelling. A State should not be able to avoid responsibility merely because other States contribute more to a global problem.

Nevertheless, the phrase that each State must “do its part” leaves unresolved the difficult question of how that part should be calculated.

Climate responsibility may be assessed through several competing criteria, including present emissions, historical emissions, per capita emissions, economic capacity, and vulnerability. The Supreme Court did not establish a universal methodology for balancing those considerations.

This limitation does not undermine the specific holding in Urgenda, but it constrains the generalisability of the judgment. The decision should not be understood as authorising courts to impose identical mitigation obligations across jurisdictions without careful consideration of the relevant legal and factual context.

Its more durable principle is narrower: limited individual contribution does not, by itself, extinguish individual legal responsibility.

E. Enforcement and Institutional Capacity

Climate judgments ultimately depend upon institutions outside the courtroom for their implementation.

A court can declare that a State has failed to meet a legal obligation, but it cannot itself construct renewable-energy infrastructure, regulate industrial emissions, or transform national transport systems. Effective implementation therefore depends upon sustained legislative and executive action.

This exposes an important limitation of climate litigation. Judicial intervention can establish accountability and compel reconsideration, but it cannot replace effective governance.

At the same time, this limitation supports rather than defeats the restrained model adopted in Urgenda. By setting a legal minimum and leaving implementation to the State, the judgment recognises the distinct institutional capacities of courts and political authorities.

VIII. Prevention, Precaution and Intergenerational Dimensions

The reasoning in Urgenda has a strongly preventive character. The Supreme Court did not require the claimants to demonstrate that catastrophic climate harm had already occurred. The existence of a serious and foreseeable risk was sufficient to engage the State’s protective obligations.[40]

The judgment should nevertheless not be inaccurately characterised as establishing a new, free-standing precautionary principle enforceable through the ECHR. The formal legal basis of the decision remained the positive obligations arising under Articles 2 and 8.

Its reasoning does, however, reflect a broader preventive logic found throughout environmental governance. Where harm may be severe, cumulative, or irreversible, legal systems cannot always postpone protective action until every consequence is fully realised or scientifically measurable with complete certainty.

The case also possesses an important intergenerational dimension. Climate decisions made by present governments may shape environmental conditions over decades. The Supreme Court did not create an autonomous doctrine of rights belonging to future generations. Nevertheless, its recognition of long-term and foreseeable risks demonstrates that existing human-rights obligations are capable of responding to threats whose most severe consequences may unfold over extended periods.

IX. Global Significance

The global significance of Urgenda lies less in the precise numerical standard upheld by the Dutch courts than in the legal framework it provides for thinking about climate accountability.

The case demonstrates that domestic human-rights law may provide a means of scrutinising governmental climate action even where international climate agreements depend substantially upon domestic implementation. It thereby connects international scientific knowledge, international climate commitments, and domestic legal duties without collapsing them into a single source of obligation.

The judgment is especially relevant to jurisdictions increasingly exposed to floods, extreme heat, drought, sea-level rise, and other climate-related risks. Such events raise difficult questions concerning the adequacy of governmental mitigation and adaptation measures and the extent to which those measures may be reviewed through existing constitutional or human-rights guarantees.

Yet Urgenda should not be treated as a universal template that can simply be replicated without adaptation. Its reasoning depended upon the ECHR, Dutch procedural law, the Netherlands’ position within the international climate framework, and the scientific evidence before the Court.

Its transferable lesson is therefore conceptual rather than mechanical: a global environmental problem can generate concrete domestic obligations, and governmental reliance upon the global scale of that problem does not necessarily defeat legal accountability.

X. Conclusion

State of the Netherlands v Stichting Urgenda represents a defining moment in the development of climate litigation because it connected the abstract threat of dangerous climate change with concrete legal duties of governmental protection.

The Supreme Court confirmed that Articles 2 and 8 ECHR can impose positive obligations upon the Dutch State to take appropriate and effective measures against serious climate-related risks. In the particular circumstances of the case, those obligations supported the minimum mitigation standard upheld by the Dutch courts.

The judgment’s importance depends as much upon what it did not decide as upon what it did. The Court did not hold that the Paris Agreement independently mandated the reduction standard at issue. It did not establish a universal target applicable to every State. Nor did it assume responsibility for determining the detailed content of Dutch climate policy.

Instead, Urgenda established a model of rights-based accountability. The judiciary defined the minimum legal standard required for the protection of Convention rights, while the political branches retained discretion over the means of compliance.

The decision is not free from difficulty. Translating scientific consensus into legal standards remains institutionally and conceptually complex. The meaning of an individual State’s obligation to “do its part” remains contested, and judicial decisions cannot substitute for effective climate governance.

Nevertheless, Urgenda demonstrates that political complexity and collective causation do not automatically place governmental climate action beyond judicial review. Its enduring contribution lies in confirming that, where serious and foreseeable environmental risks threaten fundamental rights, State discretion remains subject to legal limits.

In that sense, Urgenda is best understood not as a judicial takeover of climate policy, but as a carefully bounded assertion of constitutional accountability: governments may retain broad authority to choose how to respond to climate change, but that discretion does not necessarily extend to deciding whether to provide the minimum protection required by law.

Footnotes and Authorities

State of the Netherlands v Stichting Urgenda (Supreme Court of the Netherlands, 20 December 2019) No. 19/00135, ECLI:NL:HR:2019:2007 (English translation).
Ibid.
Convention for the Protection of Human Rights and Fundamental Freedoms (European Convention on Human Rights, as amended), arts. 2 and 8.
State of the Netherlands v Stichting Urgenda (n. 1).
State of the Netherlands v Stichting Urgenda (Opinion of the Procurator General, 13 September 2019) No. 19/00135, ECLI:NL:PHR:2019:1026.
Ibid.
Ibid.
Ibid.
Urgenda Foundation v State of the Netherlands (District Court of The Hague, 24 June 2015) ECLI:NL:RBDHA:2015:7145.
Ibid.
Ibid.; Dutch Civil Code, art. 6:162.
Urgenda Foundation v State of the Netherlands (n. 9).
Dutch Civil Code, art. 3:305a.
State of the Netherlands v Stichting Urgenda (Court of Appeal of The Hague, 9 October 2018) ECLI:NL:GHDHA:2018:2591.
Ibid.
State of the Netherlands v Stichting Urgenda (n. 5).
State of the Netherlands v Stichting Urgenda (n. 1).
State of the Netherlands v Stichting Urgenda (n. 5).
Ibid.
Ibid.
State of the Netherlands v Stichting Urgenda (n. 1).
Ibid.
Ibid.
Ibid.
Ibid.
Ibid.
Ibid.
Ibid.
Ibid.; European Convention on Human Rights (n. 3), arts. 2 and 8.
State of the Netherlands v Stichting Urgenda (n. 1).
Ibid.
Ibid.
Ibid.
United Nations Framework Convention on Climate Change (adopted 9 May 1992, entered into force 21 March 1994) 1771 UNTS 107, Annex I.
State of the Netherlands v Stichting Urgenda (n. 1).
Paris Agreement (adopted 12 December 2015, entered into force 4 November 2016), art. 2(1)(a).
State of the Netherlands v Stichting Urgenda (n. 1).
Ibid.
Ibid.
Ibid.

Primary Authorities

State of the Netherlands v Stichting Urgenda (Supreme Court of the Netherlands, 20 December 2019) No. 19/00135, ECLI:NL:HR:2019:2007 (English translation).
State of the Netherlands v Stichting Urgenda (Court of Appeal of The Hague, 9 October 2018) ECLI:NL:GHDHA:2018:2591.
Urgenda Foundation v State of the Netherlands (District Court of The Hague, 24 June 2015) ECLI:NL:RBDHA:2015:7145.
State of the Netherlands v Stichting Urgenda (Opinion of the Procurator General, 13 September 2019) No. 19/00135, ECLI:NL:PHR:2019:1026.

International Instruments

Convention for the Protection of Human Rights and Fundamental Freedoms (European Convention on Human Rights, as amended).
United Nations Framework Convention on Climate Change (adopted 9 May 1992, entered into force 21 March 1994) 1771 UNTS 107.
Paris Agreement (adopted 12 December 2015, entered into force 4 November 2016).

Legislation

Dutch Civil Code, arts. 3:305a and 6:162.

Disclaimer: The views expressed in this article are those of the author and do not necessarily reflect the views of The Lawscape.

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